30th September 2020
The Testing Phase of the CBAR system led to the FIAU and Reporting Entities identifying a number of situations where the Reporting Entities may not be in possession of the data required to complete the XML Schema due to particular situations, such as inactive or dormant accounts. This has led to Reporting Entities either being unable to complete mandatory fields or otherwise to provide data that though not mandatory the Reporting Entity would be expected to have due to the particular nature of the account holder.
In an effort to address these situations and allow for the submission of the XML Schema file, the FIAU will temporarily make available a series of workarounds for the following fields:
- Missing Date of Birth / Registration Date
- Missing Identification Document
- Missing Country
The FIAU would like to remind the reporting entities that the accuracy of data submitted is the responsibility of the reporting entity. Use of these workarounds should therefore only be made when this is strictly necessary and justified. Anyone making use of these workarounds is required to formally notify the FIAU beforehand via email on [email protected] noting the reason/s behind such discrepancies. Reporting entities are expected to take all the necessary steps to rectify the situation in subsequent submissions.
For further details, please refer to the updated technical documentation v1.4 (downloadable pack below) which now includes the aforementioned exceptions and their corresponding workaround alongside revised validation rules.
In the ensuing CBAR newsletter, we will address the issue of names for natural and non-natural persons that include a dot (e.g. ‘Joe X. Borg’ and ‘C.V. L.T.D.’) which at the moment are precluded.